Max Rack, Inc. v. Core Health & Fitness, LLC, No. 20-3600 (6th Cir. 2022)Annotate this Case
Skilken, the owner of Max Rack, Inc., invented a piece of gym equipment that he named the “Max Rack.” For years, his company sold Max Racks through a licensing agreement with Core. When Max Rack’s last patent expired, Core decided to sell an identical machine under a new name, “Freedom Rack.” Max Rack alleged that Core continued to sell “Max Racks” without authorization, and attempted to sell Freedom Racks by free-riding off the “Max Rack” name, Lanham Act, 15 U.S.C. 1114(1), 1117(a), 1125(a)(1)(A). A jury awarded Max Rack $1 million in damages and $250,000 in Core’s profits. The district court doubled the profits award to $500,000, and granted Max Rack attorney’s fees but overturned Max Rack’s damages award.
The Sixth Circuit affirmed the $250,000 profits award as supported by sufficient evidence and the court’s rejection of the $1 million damages award, reversing the court’s decision to double the profits award and its decision to grant Max Rack attorney’s fees. This case does not qualify as “exceptional” and Core did not litigate in an “unreasonable manner.” Core’s unauthorized sales ended before trial.